Reporting to the Deputy Chief Compliance Officer (Deputy CCO), position is responsible for fulfilling the day-to-day responsibilities of the compliance program for CIM’s registered and non-registered advisers, as required by applicable statutory, regulatory and ethical requirements.
Essential Functions Compliance Policies: Promulgating and administering compliance policies, including: Updating existing policies, from time to time as may be appropriate; and Providing employees with advice on interpreting the policies. Code of Ethics: Overseeing certain day to day activities, including: Managing related disclosures and preapproval requests; and Investigating violations and making enforcement recommendations to the CCO.Training, Communications and Enforcement: Implementing and conducting an effective compliance training, communications and enforcement program, including: Providing compliance related training for all levels of employees appropriate to their respective roles and responsibilities; and providing training for agents and service providers, as necessary; Disseminating communications as appropriate to convey and reinforce applicable laws and regulations, ethical standards, and compliance policies to establish a “culture of compliance”; and Undertaking monitoring activities designed to prevent and detect misconduct involving violations of the Compliance Program.AML Review: Collecting and processing information in conjunction with CIM’s KYC and AML requirements. Risk Assessment and Testing: Directing and/or participating in regular risk assessments of the activities and operations of assigned entities to establish or modify the components of the compliance program from time to time as appropriate, including: Assisting with the promulgation and revision of the risk map and risk matrix, as necessary; and preparing and implement a comprehensive compliance testing program based on the foregoing risk assessment.
Supervisory ResponsibilitiesManaging relationships with outside compliance vendors including but not limited to supporting the vetting of vendors;Overseeing email review performed by compliance personnel; andSupervising assigned compliance personnel.
RequirementsBachelor of Arts or Bachelor of Science degreeMinimum 10 years’ experience in Investment Adviser complianceKnowledge of legal and compliance terminology and concepts Knowledge of Investment Advisers Act of 1940 and Investment Company Act 1940Knowledge of Securities Exchange Act of 1934Knowledge of Bank Secrecy ActSeries 7 and Series 24 preferred but not required Proficiency in Microsoft Office including Word, Excel and OutlookExperience with Star Compliance or similar software